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In page Child support in the United States:
"Most courts addressing the issue of imprisonment for child support deficiencies since the United States Supreme Court's ruling in Lassiter vs Department of Social Services, 452 U.S. 18 (1981) have held that appointed counsel is required if the obligor's liberty is at stake. In March 2006, the Supreme Court of New Jersey, upheld this principle in the case of Anne Pasqua, et al. v. Hon. Gerald Council, et al. As of August 2006, at least four states (New Hampshire, Pennsylvania, Virginia, and South Carolina) do not consistently appoint attorneys in enforcement proceedings. As of 2011 court challenges were pending in Pennsylvania and New Hampshire.[citation needed]
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